Comment #1Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-02Page Number: 2Paragraph / Figure / Table / Note: 903.4.1.3.3.1Comment Intent: ObjectionComment Type: TechnicalComment: Need to be more specific about pictures. Eliminate the word impossible. In my opinion one should have to have the address/file name/id number-specific to that house id in the picture. It is easy to carry a small whiteboard with dry erase or a sticky note you can use in photo to show exactly which house photo is taken from. Plus a specific id in the photo eliminates using the same pictures over and over. This method is not unique to this industry. Fortified uses this same method..pic must be specific to this house and they require you to show the address in the pics. Proposed Change: 903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date and time of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • EEP Verification Checklists (-Energy Star) • RESNET Home Energy Rating Standard Disclosure • Address or unique Dwelling Unit ID shall be in each of the Photos of the following building features where applicable which are input into the approved rating software: for this specific Dwelling Unit.to the rated Dwelling Unit. (Note: Where photos are impossible or would Where photos lack sufficient detail1, the Quality Assurance Designee may, at their discretion, allow shall require additional alternative supporting documentation. such as purchase orders or receiptsbuilder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials. Collect photos with sufficient detail to confirm the thickness, type and installation grade of the insulation for each unique building assembly used in the software model. o All Hheating, Ccooling, and Sservice Hhot Wwater Eequipment including nameplate/model number o Whole House Dwelling Unit Mechanical Ventilation System Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Duck Lleakage of air ducts test result(s) for each system o Dwelling Unit Mechanical Ventilation System test result(s) for each system o The building’s Ffront, Bback, Rright, Lleft elevations o Appliances (Rrefrigerator, Ddishwasher, Wwasher, Ddryer) including nameplate/model number
Need to be more specific about pictures. Eliminate the word impossible. In my opinion one should have to have the address/file name/id number-specific to that house id in the picture. It is easy to carry a small whiteboard with dry erase or a sticky note you can use in photo to show exactly which house photo is taken from. Plus a specific id in the photo eliminates using the same pictures over and over. This method is not unique to this industry. Fortified uses this same method..pic must be specific to this house and they require you to show the address in the pics.
903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date and time of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • EEP Verification Checklists (-Energy Star) • RESNET Home Energy Rating Standard Disclosure • Address or unique Dwelling Unit ID shall be in each of the Photos of the following building features where applicable which are input into the approved rating software: for this specific Dwelling Unit.to the rated Dwelling Unit. (Note: Where photos are impossible or would Where photos lack sufficient detail1, the Quality Assurance Designee may, at their discretion, allow shall require additional alternative supporting documentation. such as purchase orders or receiptsbuilder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials. Collect photos with sufficient detail to confirm the thickness, type and installation grade of the insulation for each unique building assembly used in the software model. o All Hheating, Ccooling, and Sservice Hhot Wwater Eequipment including nameplate/model number o Whole House Dwelling Unit Mechanical Ventilation System Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Duck Lleakage of air ducts test result(s) for each system o Dwelling Unit Mechanical Ventilation System test result(s) for each system o The building’s Ffront, Bback, Rright, Lleft elevations o Appliances (Rrefrigerator, Ddishwasher, Wwasher, Ddryer) including nameplate/model number
Comment #2Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-02Page Number: 2Paragraph / Figure / Table / Note: 903.4.1.3.3.1Comment Intent: ObjectionComment Type: TechnicalComment: Need to specify how long QA designee shall maintain QA file Proposed Change: 903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect, and review, and maintain (for a period of 3 years) the following supporting documentation for each file QA:
Need to specify how long QA designee shall maintain QA file
903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect, and review, and maintain (for a period of 3 years) the following supporting documentation for each file QA:
Comment #3Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-02Page Number: 21Paragraph / Figure / Table / Note: 903.4.1.3.3.1Comment Intent: Not an ObjectionComment Type: EditorialComment: Fix the typo "duck" to "duct." Proposed Change: o Duckt leakage test result(s) for each system
Fix the typo "duck" to "duct."
o Duckt leakage test result(s) for each system
Comment #4Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-02Page Number: 2Paragraph / Figure / Table / Note: 903.4.1.3.3.1Comment Intent: ObjectionComment Type: GeneralComment: The RESNET industry, through the standards development process, has accepted that requiring photos from ratings is a good practice and will increase the acceptance of a HERS Score as the Gold Standard for Quality Assurance. However, requiring photos of thickness, type, and grading of each unique modeled building assembly used in the software model would be quite an added cost of labor and data in storing, uploading and sharing files between raters and QA providers. Rating companies from the ELC Standards Working Group have been following the ANSI/RESNET 301-20XX Appendix B requirements since they were published, and found that uploading those photos in an organized fashion that is efficient enough to share with others takes a fair amount of time. Requiring 5 to 10 times the amount of photos (which can sometimes be needed to accurately depict thickness, type, and grading of an assembly) will require many more photos and much more added time in data uploads, as well as time for the QAD to sort through which photos belong to which modeled assembly. On 100% of ratings performed by a rater this requirement will really add up fast. (note: While the standard requirement is normally only 1 in 10 for file review, realistically a rater can not always go back to a house chosen for QA to collect all of these photos. Therefore, to perform correctly, the proposed amendment will realistically force a rater to collect this on 100% of ratings). Data validation is important, but allowing raters to efficiently collect and then share this information is equally important. The biggest problem with the proposed amount of potential photos is when raters are looking to help builders market homes with above code verification, they are looking to do so without a lot of added cost to the builder. Bottom line, capturing this amount of photos on every house will add costs to a rater, forcing them to either consider raising their price (and potentially losing business) or moving away from using HERS as an above code verification method. Along that same vein of thought, another concern we have is that without any enforcement mechanism in place from RESNET, some QA providers may never need to follow this requirement. What would prevent a provider from having stock photos to easily share “in case of audit” that can be edited to appear as if they were taken during the required QA file (as some of us writing this comment that are QADs can attest, we have literally thousands of already taken photos stored in our files). As a result, the providers that do elect to follow this on 100% of ratings could be potentially undercut in the market. If RESNET requests photos from a provider, how are they going to remotely verify that those photos are true to that house in every instance in a practical manner? This added administrative expense could only be justified if there were truly an enforcement mechanism in place from RESNET that would provide confidence that all QA Providers are playing by the same rules. The ANSI process has already determined what the industry is willing to accept in the form of photos and the compromise that was made in that process was a few key photos reflected in ANSI/RESENT 301-20XX Appendix B. With that in mind, there is an opportunity here to strike a balance, while still making things a bit more stringent, and be effective with everyone’s time. For now, we would propose that RESNET SDC 900 direct that QA providers require the same list of photos for building assemblies listed in ANSI/RESNET 301-20XX Appendix B. Out of respect for the Standard Development Process, we have these edits below in line with this proposal only to those sections of Addendum 34 that were under review. We acknowledge that some parts of our proposal below from Addendum 34 are still in excess of what is reflected in ANSI/RESNET 301-20XX Appendix B, but those are not available for comment at this time. Additionally, we have added a clarifying remark to the informative note for when photos would lack sufficient detail to account for building features not present at the time of inspection. We would like to make it known that we will be requesting another amendment for a standard change to address this above concern for those sections of Addendum 34 that have been finalized as of PDS-02, in order to fully align MINHERS Chapter 9 with ANSI/RESNET 301-20XX Appendix B. The objective of this future proposed amendment would make it clear that the same data to be validated on site by the Rater either through an electronic copy of a checklist, data collection form, additional supporting documentation, or photo as proof of field verification is what is being requested by a QAD for 10% File Review. We believe that this would strike a balance between requiring that raters document that each feature was verified, but not require a bunch of administrative overhead in storing and sharing so many photos. As the purpose of this Addendum is to help increase industry confidence in RESNET’s QA process, we think it should be done in a practical manner to ensure it is ultimately successful and actually carried out. Finally, we plan on proposing to the correct point of contact either with RESNET Staff or the RESNET Board, that if the RESNET standards are going to require that these photos be collected, that RESNET must develop a way for them to be uploaded to the registry for every file and field QA moving forward once that tool is developed. Once this is created, RESNET will have an enforcement mechanism to randomly check in on providers and ensure that the correct process for photos is being followed. Requiring such a consistent flow of information to RESNET would make cheating on this process much more difficult for raters and providers, increasing the likelihood they will just comply. If this future proposal were to be adopted and tool developed, then requiring less photos at this juncture would be in the best interest of RESNET. We as an industry can always make requirements more stringent in the future, but it would be more difficult to reduce stringency and still maintain credibility as an industry after the fact. We urge SDC 900 to take the proper steps to set everyone up for success in the RESNET network in adopting these changes. This public comment was developed via a consensus process from among members from the ELC Standards Working Group, which as of this public comment represents the below companies. EnergyLogic Energy Diagnostics Energy Efficient Homes Midwest Steven Winters Associates Home Energy Group Eco Achievers Proposed Change: 903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: Date and time of the inspection/test The name of the Certified Rater or RFI conducting the inspection/test Plans (or alternative documentation showing building dimensions) EEP Verification Checklists (Energy Star) RESNET Home Energy Rating Standard Disclosure Photos of the following building features where applicable to the rated Dwelling Unit. (Note: Where photos are impossible or would lack sufficient detail1, the Quality Assurance Designee may, at their discretion, allow shall require additional alternative supporting documentation. such as purchase orders or receiptsbuilder spec sheet) ?Each unique building assembly depicting assembly thickness and R value/insulation materials Collect photos with sufficient detail to confirm the thickness, type and installation grade of the insulation for each unique building assembly used in the software model. Building assemblies as described in the latest published version of ANSI/RESNET 301-20XX Appendix B Inspection Procedures for Minimum Rated Features. All Hheating, Ccooling, and Sservice Hhot Wwater Eequipment including nameplate/model number Whole House Dwelling Unit Mechanical Ventilation System Equipment including nameplate/model number and controls Infiltration test result or automated test report Duckt Lleakage of air ducts test result(s) for each system Dwelling Unit Mechanical Ventilation System test result(s) for each system The building’s Ffront, Bback, Rright, Lleft elevations Appliances (Rrefrigerator, Ddishwasher, Wwasher, Ddryer) including nameplate/model number 1. (Informative Note) For example, where equipment is located in narrow utility closets that prohibit clear photo of nameplate/model number., or when the building feature required is not present at the time of inspection.
The RESNET industry, through the standards development process, has accepted that requiring photos from ratings is a good practice and will increase the acceptance of a HERS Score as the Gold Standard for Quality Assurance. However, requiring photos of thickness, type, and grading of each unique modeled building assembly used in the software model would be quite an added cost of labor and data in storing, uploading and sharing files between raters and QA providers. Rating companies from the ELC Standards Working Group have been following the ANSI/RESNET 301-20XX Appendix B requirements since they were published, and found that uploading those photos in an organized fashion that is efficient enough to share with others takes a fair amount of time. Requiring 5 to 10 times the amount of photos (which can sometimes be needed to accurately depict thickness, type, and grading of an assembly) will require many more photos and much more added time in data uploads, as well as time for the QAD to sort through which photos belong to which modeled assembly. On 100% of ratings performed by a rater this requirement will really add up fast. (note: While the standard requirement is normally only 1 in 10 for file review, realistically a rater can not always go back to a house chosen for QA to collect all of these photos. Therefore, to perform correctly, the proposed amendment will realistically force a rater to collect this on 100% of ratings).
Data validation is important, but allowing raters to efficiently collect and then share this information is equally important. The biggest problem with the proposed amount of potential photos is when raters are looking to help builders market homes with above code verification, they are looking to do so without a lot of added cost to the builder. Bottom line, capturing this amount of photos on every house will add costs to a rater, forcing them to either consider raising their price (and potentially losing business) or moving away from using HERS as an above code verification method. Along that same vein of thought, another concern we have is that without any enforcement mechanism in place from RESNET, some QA providers may never need to follow this requirement. What would prevent a provider from having stock photos to easily share “in case of audit” that can be edited to appear as if they were taken during the required QA file (as some of us writing this comment that are QADs can attest, we have literally thousands of already taken photos stored in our files). As a result, the providers that do elect to follow this on 100% of ratings could be potentially undercut in the market. If RESNET requests photos from a provider, how are they going to remotely verify that those photos are true to that house in every instance in a practical manner? This added administrative expense could only be justified if there were truly an enforcement mechanism in place from RESNET that would provide confidence that all QA Providers are playing by the same rules.
The ANSI process has already determined what the industry is willing to accept in the form of photos and the compromise that was made in that process was a few key photos reflected in ANSI/RESENT 301-20XX Appendix B. With that in mind, there is an opportunity here to strike a balance, while still making things a bit more stringent, and be effective with everyone’s time. For now, we would propose that RESNET SDC 900 direct that QA providers require the same list of photos for building assemblies listed in ANSI/RESNET 301-20XX Appendix B. Out of respect for the Standard Development Process, we have these edits below in line with this proposal only to those sections of Addendum 34 that were under review. We acknowledge that some parts of our proposal below from Addendum 34 are still in excess of what is reflected in ANSI/RESNET 301-20XX Appendix B, but those are not available for comment at this time. Additionally, we have added a clarifying remark to the informative note for when photos would lack sufficient detail to account for building features not present at the time of inspection.
We would like to make it known that we will be requesting another amendment for a standard change to address this above concern for those sections of Addendum 34 that have been finalized as of PDS-02, in order to fully align MINHERS Chapter 9 with ANSI/RESNET 301-20XX Appendix B. The objective of this future proposed amendment would make it clear that the same data to be validated on site by the Rater either through an electronic copy of a checklist, data collection form, additional supporting documentation, or photo as proof of field verification is what is being requested by a QAD for 10% File Review. We believe that this would strike a balance between requiring that raters document that each feature was verified, but not require a bunch of administrative overhead in storing and sharing so many photos. As the purpose of this Addendum is to help increase industry confidence in RESNET’s QA process, we think it should be done in a practical manner to ensure it is ultimately successful and actually carried out.
Finally, we plan on proposing to the correct point of contact either with RESNET Staff or the RESNET Board, that if the RESNET standards are going to require that these photos be collected, that RESNET must develop a way for them to be uploaded to the registry for every file and field QA moving forward once that tool is developed. Once this is created, RESNET will have an enforcement mechanism to randomly check in on providers and ensure that the correct process for photos is being followed. Requiring such a consistent flow of information to RESNET would make cheating on this process much more difficult for raters and providers, increasing the likelihood they will just comply. If this future proposal were to be adopted and tool developed, then requiring less photos at this juncture would be in the best interest of RESNET. We as an industry can always make requirements more stringent in the future, but it would be more difficult to reduce stringency and still maintain credibility as an industry after the fact. We urge SDC 900 to take the proper steps to set everyone up for success in the RESNET network in adopting these changes.
This public comment was developed via a consensus process from among members from the ELC Standards Working Group, which as of this public comment represents the below companies.
EnergyLogic Energy Diagnostics Energy Efficient Homes Midwest Steven Winters Associates Home Energy Group Eco Achievers
903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA:
1. (Informative Note) For example, where equipment is located in narrow utility closets that prohibit clear photo of nameplate/model number., or when the building feature required is not present at the time of inspection.
Comment #5Amendment: Proposed MINHERS Addendum 34, QA Data File, Draft PDS-02Page Number: allComment Intent: Not an ObjectionComment Type: TechnicalComment: I suggest the addition of clarifying language highlighted below. Proposed Change: 903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date and time of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • Calculations of building areas and volumes(Takeoffs) • EEP Verification Checklists (Energy Star) • RESNET Home Energy Rating Standard Disclosure • Photos of the following building features where applicable to the rated Dwelling Unit. (Note: Where photos are impossible or would lack sufficient detail1 , the Quality Assurance Designee may, at their discretion, allow shall require additional alternative supporting documentation2. such as purchase orders or receiptsbuilder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials Collect photos with sufficient detail to confirm the thickness, type and installation grade of the insulation for each unique building assembly used in the software model. o All Hheating, Ccooling, and Sservice Hhot Wwater Eequipment including nameplate/model number o Whole House Dwelling/Sleeping Unit Mechanical Ventilation System Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Duck Lleakage of air ducts test result(s) for each system Duct, not duck o Dwelling/Sleeping Unit Mechanical Ventilation System test result(s) for each system o The building’s Ffront, Bback, Rright, Lleft elevations One elevation must show address or lot number legibly. o Appliances (Rrefrigerator, Ddishwasher, Wwasher, Ddryer) including nameplate/model number, also Range/Stove showing fuel and if convection oven or Induction cook top • AHRI Certificates used for mechanical equipment specs • Supporting documentation for appliance specs 1. (Informative Note) For example, where equipment is located in narrow utility closets that prohibit clear photo of nameplate/model number. 2. A field data collection form completed by Rater/RFI is an acceptable alternative to photos
I suggest the addition of clarifying language highlighted below.
903.4.1.3.3.1 At minimum, the Quality Assurance Designee shall collect and review the following supporting documentation for each file QA: • Date and time of the inspection/test • The name of the Certified Rater or RFI conducting the inspection/test • Plans (or alternative documentation showing building dimensions) • Calculations of building areas and volumes(Takeoffs) • EEP Verification Checklists (Energy Star) • RESNET Home Energy Rating Standard Disclosure • Photos of the following building features where applicable to the rated Dwelling Unit. (Note: Where photos are impossible or would lack sufficient detail1 , the Quality Assurance Designee may, at their discretion, allow shall require additional alternative supporting documentation2. such as purchase orders or receiptsbuilder spec sheet) o Each unique building assembly depicting assembly thickness and R value/insulation materials Collect photos with sufficient detail to confirm the thickness, type and installation grade of the insulation for each unique building assembly used in the software model. o All Hheating, Ccooling, and Sservice Hhot Wwater Eequipment including nameplate/model number o Whole House Dwelling/Sleeping Unit Mechanical Ventilation System Equipment including nameplate/model number and controls o Infiltration test result or automated test report o Duck Lleakage of air ducts test result(s) for each system Duct, not duck o Dwelling/Sleeping Unit Mechanical Ventilation System test result(s) for each system o The building’s Ffront, Bback, Rright, Lleft elevations One elevation must show address or lot number legibly. o Appliances (Rrefrigerator, Ddishwasher, Wwasher, Ddryer) including nameplate/model number, also Range/Stove showing fuel and if convection oven or Induction cook top • AHRI Certificates used for mechanical equipment specs • Supporting documentation for appliance specs
1. (Informative Note) For example, where equipment is located in narrow utility closets that prohibit clear photo of nameplate/model number. 2. A field data collection form completed by Rater/RFI is an acceptable alternative to photos
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